Proposed Guidance Note: APES GN 41
Management Representations
Prepared and issued by
Accounting Professional & Ethical Standards Board Limited
EXPOSURE DRAFT 05/15
ISSUED: November 2015
Copyright © 2015 Accounting Professional & Ethical Standards Board Limited (“APESB”). All rights reserved. Apart
from fair dealing for the purpose of study, research, criticism and review as permitted by the Copyright Act 1968, no
part of these materials may be reproduced, modified, or reused or redistributed for any commercial purpose, or
distributed to a third party for any such purpose, without the prior written permission of APESB.
Any permitted reproduction including fair dealing must acknowledge APESB as the source of any such material
reproduced and any reproduction made of the material must include a copy of this original notice.
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APES GN 41 Management Representations
Commenting on this Exposure Draft
This Exposure Draft, APES GN 41 Management Representations was developed and
approved by the Accounting Professional & Ethical Standards Board Limited (APESB).
The proposals in this Exposure Draft may be modified in light of comments received before
being issued in final form. Comments are requested by 29 February 2016.
Comments should be addressed to:
The Chairman
Accounting Professional & Ethical Standards Board Limited
Level 7, 600 Bourke Street
MELBOURNE VIC 3000
AUSTRALIA
APESB would prefer that respondents express a clear overall opinion on whether the
proposed Guidance Note, as a whole, is supported and that this opinion be supplemented by
detailed comments, whether supportive or critical, on any matter. APESB regards both critical
and supportive comments as essential to a balanced view of the proposed Guidance Note.
Respondents are asked to submit their comments electronically through the APESB website,
using the link http://www.apesb.org.au/apesb-exposure-drafts-open-for-comment.
Please submit comments in both a PDF and Word file. All comments will be considered a
matter of public record and will ultimately be posted on the website www.apesb.org.au.
APESB prefers that comments are submitted via its website. However, if there are practical
difficulties, comments can also be sent to [email protected] or mailed to the address noted
above.
Obtaining a copy of this Exposure Draft
This Exposure Draft is available on the APESB website: www.apesb.org.au. Alternatively, any
individual or organisation may obtain one printed copy of this Exposure Draft without charge
until 29 February 2016 by contacting:
Accounting Professional & Ethical Standards Board Limited
Level 7
600 Bourke Street
Melbourne Victoria 3000
Australia
E-mail: [email protected]
Phone: (03) 9670 8911
Fax:
(03) 9670 5611
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APES GN 41 Management Representations
Reasons for issuing Exposure Draft 05/15
Accounting Professional & Ethical Standards Board Limited (APESB) proposes to issue the
Guidance Note APES GN 41 Management Representations (APES GN 41) to provide
guidance to a Member in Business, particularly a chief financial officer, senior finance
personnel and/or other senior finance personnel, in understanding the Member’s professional
and ethical obligations associated with preparing and/or signing Management
Representations to Those Charged with Governance or an external party.
Key requirements and guidance in ED 05/15
The proposed APES GN 41 provides guidance in respect of making Management
Representations to Those Charged with Governance or an external party. The proposed
Guidance Note includes guidance in respect of:

Fundamental responsibilities of Members in Business;

Professional obligations in respect of Management Representations;

Management Representation considerations at the entity level;

Management Representation considerations at the controlling entity level;

Management Representation considerations at the board or audit committee level;
and

Documentation.
Proposed operative date
It is intended that this Guidance Note will be operative when issued.
iii
APES GN 41 Management Representations
Prepared and issued by
Accounting Professional & Ethical Standards Board Limited
ISSUED: xxx 2016
Copyright © 2015 Accounting Professional & Ethical Standards Board Limited (“APESB”). All rights reserved. Apart from fair
dealing for the purpose of study, research, criticism and review as permitted by the Copyright Act 1968, no part of these
materials may be reproduced, modified, or reused or redistributed for any commercial purpose, or distributed to a third party
for any such purpose, without the prior written permission of APESB.
Any permitted reproduction including fair dealing must acknowledge APESB as the source of any such material reproduced
and any reproduction made of the material must include a copy of this original notice.
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APES GN 41 Management Representations
Contents
Section
Scope and application ............................................................................................................... 1
Definitions ................................................................................................................................. 2
Fundamental responsibilities of Members in Business ............................................................. 3
Professional obligations in respect of Management Representations ...................................... 4
Management Representation considerations at the entity level ................................................ 5
Management Representation considerations at the controlling entity level .............................. 6
Management Representation considerations at the board or audit committee level ................ 7
Documentation........................................................................................................................... 8
Conformity with International Pronouncements
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APES GN 41 Management Representations
1.
Scope and application
1.1
The objective of APES GN 41 Management Representations is to provide guidance to
a Member in Business in respect of professional and ethical obligations relating to:
 the preparation and/or signing of Management Representations;
 Management Representation considerations at the entity level, controlling entity
level and board or audit committee level; and
 professional obligations (due to regulatory practice or other conventions) in relation
to Management Representations and Financial Reporting Certifications.
APES GN 41 does not set out the underlying procedures or processes to be followed
by a Member in order to comply with applicable regulatory or other obligations
associated with Management Representations.
1.2
Accounting Professional & Ethical Standards Board Limited (APESB) issues
professional guidance note APES GN 41 Management Representations (the Guidance
Note) which is effective from the date of issue.
1.3
APES GN 41 provides guidance to Members in Business, particularly chief financial
officers, senior finance personnel and/or other senior finance personnel, in
understanding their professional and ethical obligations associated with preparing
and/or signing Management Representations to Those Charged with Governance or
an external party. This Guidance Note does not prescribe or create any mandatory
requirements.
1.4
Members in Business using this Guidance Note should refer to APESB’s Due process
and working procedures for the development and review of APESB pronouncements.
1.5
Members in Business working outside of Australia should follow the guidance in APES
GN 41 to the extent to which they are not prevented from doing so by specific
requirements of local laws and/or regulations.
1.6
The Guidance Note is not intended to detract from any responsibilities which may be
imposed by law or regulation.
1.7
All references to Professional Standards, guidance notes and legislation are
references to those provisions as amended from time to time.
1.8
Members in Business are required to be familiar with relevant Professional Standards
and guidance notes when performing Professional Activities for Employers.
1.9
In applying the guidance outlined in APES GN 41, Members in Business should be
guided not merely by the words but also by the spirit of this Guidance Note and the
Member’s professional obligation to comply with the requirements of the Code.
1.10 In this Guidance Note, unless otherwise specified, words in the singular include the
plural and vice versa, words of one gender include another gender, and words
referring to persons include corporations or organisations, whether incorporated or not.
2.
Definitions
For the purpose of this Guidance Note:
Applicable Financial Reporting Framework means the financial reporting framework
adopted by management and, where appropriate, Those Charged with Governance in the
preparation of the financial report that is acceptable in view of the nature of the entity and the
objective of the financial report, or that is required by law or regulation.
The term fair presentation framework means a financial reporting framework that requires
compliance with the requirements of the framework and:
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APES GN 41 Management Representations
(a) Acknowledges explicitly or implicitly that, to achieve fair presentation of the financial
report, it may be necessary for management to provide disclosures beyond those
specifically required by the framework; or
(b) Acknowledges explicitly that it may be necessary for management to depart from a
requirement of the framework to achieve fair presentation of the financial report. Such
departures are expected to be necessary only in extremely rare circumstances.
In the context of financial reporting, the term compliance framework means a financial
reporting framework that requires compliance with the requirements of the applicable
framework, but does not contain the acknowledgements in (a) or (b) above.
Code means APES 110 Code of Ethics for Professional Accountants.
Employer within the context of this Guidance Note means an entity or person that employs,
engages or contracts a Member in Business.
Fraud means an intentional act by one or more individuals among management, Those
Charged with Governance, employees or third parties, involving the use of deception to
obtain an unjust or illegal advantage.
Financial Statements mean a structured representation of historical financial information,
including related notes, intended to communicate an entity’s economic resources or
obligations at a point in time or the changes therein for a period of time in accordance with a
financial reporting framework. The related notes ordinarily comprise a summary of significant
accounting policies and other explanatory information. The term can relate to a complete set
of Financial Statements, but it can also refer to a single Financial Statement, for example, a
balance sheet, or a statement of revenues and expenses, and related explanatory notes. The
requirements of the financial reporting framework determine the form and content of the
Financial Statements and what constitutes a complete set of Financial Statements.
Financial Reporting Certification means a declaration provided by the chief executive
officer and chief financial officer to Those Charged with Governance in relation to an entity’s
Financial Statements.
Group Financial Report means a financial report that includes the financial information of
more than one component. The term “Group Financial Report” also refers to combined
financial reports aggregating the financial information prepared by components that have no
parent but are under common control.
Group Management means management, or Those Charged with Governance, responsible
for the preparation of the Group Financial Report.
Internal Control means the process designed, implemented and maintained by Those
Charged with Governance, management and other personnel to provide reasonable
assurance about the achievement of an entity’s objectives with regard to reliability of financial
reporting, effectiveness and efficiency of operations, and compliance with applicable laws
and regulations. The term “controls” refers to any aspects of one or more of the components
of Internal Control.
Management’s Expert means an individual or organisation possessing expertise in a field
other than accounting, whose work in that field is used by management of the entity to assist
the entity in preparing the financial report.
Management Representations means a written statement by management provided to
Those Charged with Governance or external parties to confirm certain matters or to support
evidence. Management Representations in this context do not include the financial report, the
assertions therein, or supporting books and records.
Member means a member of a Professional Body that has adopted this Guidance Note as
applicable to their membership as defined by that Professional Body.
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APES GN 41 Management Representations
Member in Business means a Member employed or engaged in an executive or nonexecutive capacity in such areas as commerce, industry, service, the public sector,
education, the not for profit sector, regulatory bodies or professional bodies, or a Member
contracted by such entities.
Member in Public Practice means a Member, irrespective of functional classification (e.g.
audit, tax or consulting) in a firm that provides professional services. This term is also used to
refer to a firm of Members in Public Practice and means a practice entity and a participant in
that practice entity as defined by the applicable Professional Body.
Misstatement means a difference between the amount, classification, presentation, or
disclosure of a reported item in financial information, and the amount, classification,
presentation, or disclosure that is required for the item to be in accordance with the
Applicable Financial Reporting Framework. Misstatements can arise from error or Fraud.
Where the financial information is prepared in accordance with a fair presentation framework,
Misstatements also include those adjustments of amounts, classifications, presentation, or
disclosures that, in the judgement of the Member in Business, are necessary for the financial
information to be presented fairly, in all material respects.
Outsourcing means an activity where an entity engages a party, on a continuing basis, to
perform a business activity that is being, has been, or could be performed by that entity.
Outsourced Service Provider means an entity including a person that is providing services
in accordance with an Outsourcing agreement. The Outsourced Service Provider may not be
located in the same country as the Member in Business and may not even be a Member.
Professional Activity means an activity requiring accountancy or related skills undertaken
by a Member, including accounting, auditing, taxation, management consulting, and financial
management.
Professional Bodies means Chartered Accountants Australia and New Zealand, CPA
Australia and the Institute of Public Accountants.
Professional Standards means all standards issued by Accounting Professional & Ethical
Standards Board Limited and all professional and ethical requirements of the applicable
Professional Body.
Risk means the effect of uncertainty on objectives.
1
2
Risk Management Framework means the foundations and organisational arrangements
for designing, implementing, monitoring, reviewing and continually improving Risk
management throughout the entity.
Those Charged with Governance means the persons or organisation(s) (for example, a
corporate trustee) with responsibility for overseeing the strategic direction of the entity and
obligations related to the accountability of the entity. This includes overseeing the financial
reporting process. For some entities in some jurisdictions, Those Charged with Governance
may include management personnel, for example, executive members of a governance
board of a private or public sector entity, or an owner-manager.
3.
Fundamental responsibilities of Members in Business
3.1
The Code is the conceptual framework and foundation upon which all APESB
pronouncements are based. Compliance with and application of the Code is
fundamental to the ethical behaviour of Members in Business. Non-compliance with the
Code can lead to disciplinary proceedings being initiated by the Professional Body to
which the Member belongs.
1
2
The foundations include the policy, objectives, mandate and commitment to manage Risk.
The organisational arrangements include plans, relationships, accountabilities, resources, processes and activities.
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APES GN 41 Management Representations
3.2
A Member in Business who performs a Professional Activity, including a Member who
provides Management Representations to Those Charged with Governance or external
parties on Financial Statements or other relevant matters, is required to comply with
Part A – General Application of the Code and Part C – Members in Business, and
applicable laws or regulations.
4.
Professional
obligations
Representations
4.1
Management Representations provided by Members in Business to Those Charged
with Governance or external parties include, but are not limited to:
in
respect
of
Management
External Management Representations
(a) written representations provided to Members in Public Practice (e.g. external
auditors) in respect of annual Financial Statements and half-year Financial
3,4
Statements ;
(b) Management Representations provided to Members in Public Practice in respect
of a compilation engagement;
(c) Management Representations provided to an Employer or Members in Public
Practice in respect of a valuation service;
(d) Management Representations provided to an Employer or Members in Public
Practice in respect of a due diligence committee e.g. acquisitions, divestments,
restructuring or raising finance from capital and debt markets;
(e) Management Representations provided to rating agencies or similar organisations
who are performing evaluations of the organisation’s financial capacity and
stability or governance arrangements;
(f)
Management Representations provided to an organisation’s financiers or lenders
when obtaining finance or in respect of ongoing compliance with loan covenants;
Internal Management Representations
(g) Financial Reporting Certifications including Internal Control questionnaires; or
(h) declarations provided to the board/audit committee of a local or foreign jurisdiction
in accordance with the respective jurisdiction’s regulations.
4.2
Members in Business should prepare or present Management Representations in a
manner that is fair and honest, in accordance with applicable Professional Standards
and where applicable, in accordance with the Applicable Financial Reporting
Framework. This includes preparing or presenting Management Representations in a
manner that is intended:
(a) to neither mislead nor to influence contractual or regulatory outcomes
inappropriately; and
(b) to not omit information which would cause the Management Representations to be
misleading.
4.3
3
4
When presenting information, Members in Business are required to comply with
section 320 Preparation and Reporting of Information of the Code. Members should
consider the purpose of the Management Representations, the context and its users.
Corporations Act 2001: sections 295A, 300A and 312.
Auditing and Assurance Standards Board. Auditing Standard ASA 580 Written Representations.
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APES GN 41 Management Representations
4.4
Where a Member in Business prepares and/or signs Management Representations,
the Member is required to comply with section 330 Acting with Sufficient Expertise of
the Code. The Member is required to maintain professional knowledge and skill at the
level required and should be knowledgeable of the entity’s industry and other relevant
matters to ensure the Member’s Employer receives competent professional advice.
The Member is required to have, or obtain sufficient specific training or experience,
and possess sufficient time and adequate resources to complete the Management
Representations within the reporting deadline.
Relying on the work of others
4.5
Where a Member in Business relies on the work of others (e.g. Management’s Expert,
Outsourced Service Provider or internal personnel) to provide Management
Representations, the Member should take reasonable steps to be satisfied that such
work enables the Member to fulfil the obligations set out in paragraph 4.2.
4.6
Where a Member in Business has determined that the work of others may include a
Misstatement or that the Management Representations are misleading, the Member
should take qualitative as well as quantitative factors into consideration when
evaluating the significance of the suspected Misstatement or the potentially misleading
Management Representations. The Member should consider undertaking the following
procedures:
(a) making enquiries of the work of others to assess the reliability, accuracy and
completeness of Management Representations provided; or
(b) performing verification procedures on the relevant matter; and
(c) reassessing the suspected Misstatement or potentially misleading Management
Representations on an ongoing basis.
Confidentiality and disclosure
4.7
Where a Member in Business is considering disclosing confidential information
acquired in the course of providing Professional Activities, the Member is required to
comply with section 140 Confidentiality of the Code. The Member should also refer to
the guidance in section 12 Disclosure of information and whistleblowing of APES GN
40 Ethical Conflicts in the Workplace - Considerations for Members in Business.
5.
Management Representation considerations at the entity level
5.1
A Member in Business who prepares or who is responsible for Management
Representations at the entity level should take reasonable steps to:
(a) record, classify and maintain information in a timely manner that:
(i)
describes the true nature of business transactions, assets or liabilities; and
(ii)
represents the facts, accurately and completely in all material respects.
(b) where the entity is part of a group, communicate the group policies and
procedures (including any changes) in respect of financial reporting to the entity’s
personnel in a timely manner.
(c) oversee or obtain comfort regarding the recruitment and selection process of
finance personnel who possess the relevant skills and expertise to perform their
tasks with integrity and objectivity.
(d) develop the competence of personnel who are to complete the Management
Representations checklist that includes:
(i)
continuing professional development on Professional Standards, legal
obligations and other regulations (e.g. insider trading, corporate governance,
applicable accounting, and auditing and assurance standards);
(ii)
providing relevant work experience to continuously develop their skills, and
(iii) coaching of junior personnel by more experienced personnel.
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APES GN 41 Management Representations
5.2
During the Management Representation process, a Member in Business may
encounter circumstances that may create threats to compliance with the fundamental
principles of the Code. These circumstances include:
(a) business transactions or activities that impair or might impair the entity’s and
group’s good reputation;
(b) potential accounting and tax transactions or arrangements which may not be in
accordance with applicable legal and regulatory requirements;
(c) arrangements which involve documents or accounting entries that are intended to
misrepresent a transaction or which is dependent upon its lack of disclosure for its
effectiveness; or
(d) potential unethical conduct, or non-compliance with applicable legal and
regulatory obligations.
In these circumstances, the Member in Business should take appropriate action in
accordance with the entity’s or group’s policies and procedures, or alternatively inform
Group Management or Those Charged with Governance to enable them to take
appropriate action to eliminate the threat or reduce the threat to an acceptable level.
5.3
A Member in Business should take reasonable steps to make Management
Representations with integrity and objectivity regardless of the outcome of the
Management Representation process.
5.4
A Member in Business should report actual or potential Internal Control weaknesses in
the entity’s Internal Control environment to Group Management or Those Charged with
Governance, as appropriate.
6.
Management Representation considerations at the controlling
entity level
6.1
A Member in Business who prepares and/or reviews the group Management
Representations at the controlling entity level should establish policies and procedures
designed to provide Those Charged with Governance with reasonable confidence that
the group Management Representations are appropriate, including:
(a) promoting consistency in the group Management Representation process;
(b) assisting and/or supervising the group Management Representation process;
(c) reviewing the group Management Representation process; and
(d) taking reasonable steps to create an organisational culture and environment of
compliance with the applicable group reporting requirements.
6.2
The responsibilities of a Member in Business who is assisting and/or supervising the
group Management Representation process may include:
(a) monitoring its progress;
(b) considering the ability of the personnel to support the Member’s compliance with
the professional and ethical requirements of the Code;
(c) considering the skills, competency, capabilities and knowledge of the personnel
involved and whether they understand group reporting instructions;
(d) guiding personnel to complete the Management Representations;
(e) assessing whether it is carried out in accordance with the group policies and
procedures;
(f)
addressing significant matters or discrepancies arising; and
(g) assessing the completeness of group Management Representations.
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APES GN 41 Management Representations
6.3
The responsibilities of a Member in Business who is reviewing the group Management
Representation process may include:
(a) ensuring personnel with the relevant skills, knowledge and abilities are overseeing
the group Management Representations;
(b) performing sufficient enquiries and reviews to ensure that entities (notwithstanding
the complex group structures) are in compliance with the group accounting
policies and group Management Representation processes;
(c) obtaining reasonable confidence of the validity and reliability of the Management
Representations (e.g. sample reviews by internal audit or the Member in
Business); and
(d) determining if discrepancies exist between Internal Control matters reported by
the internal auditor, external auditor and the entity’s Management
Representations.
6.4
Where a Member in Business identifies Internal Control weaknesses, Fraud,
irregularities, suspected non-compliance with laws and regulations or potential issues
that may have not been dealt with by management previously, the Member should
consider:
(a) providing appropriate guidance for personnel to communicate within the group in
respect of potential next steps including reporting such matters, where material, to
Those Charged with Governance;
(b) taking reasonable steps to ensure that the identified issues are being dealt with
appropriately by the relevant personnel;
(c) taking reasonable steps to ensure appropriate remedial action is being taken to
resolve issues identified by the external auditors and internal auditors (in
particular, noting issues which may be pervasive); and
(d) documenting and reporting to Those Charged with Governance on how material
contentious matters are being resolved, such as non-compliance with laws and
regulations or Risk management issues.
Financial Reporting Certification considerations
6.5
A Member in Business should perform an assessment of how the organisation’s
Internal Control environment and the financial reporting framework support the group’s
Financial Reporting Certification.
6.6
A Member in Business who uses an Internal Control questionnaire or equivalent as a
confirmation process to obtain evidence and reasonable confidence regarding the
integrity of the Group Financial Report or to test the operating effectiveness of the
Internal Control environment, should consider:
(a) tailoring the Internal Control questionnaire so that it is appropriate, relevant and
directed at significant areas of each entity; and
(b) requesting feedback from each entity on significant Risks that impact the Group
Financial Report.
6.7
A Member in Business should consider the roles and responsibilities of all
stakeholders in the group financial reporting or in the group Financial Reporting
Certification process by:
(a) regularly assessing the group Financial Reporting Certification;
(b) communicating and explaining to personnel the requirements and importance of
the group Financial Reporting Certification, and the role the group Internal Control
environment plays; and
(c) reviewing the evidence provided by entities’ management to support the group
Financial Reporting Certification and ensuring its consistency with the overall view
of the entity and its operations.
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APES GN 41 Management Representations
6.8
A Member in Business who is required to provide a group Financial Reporting
Certification to Those Charged with Governance should:
(a) review Internal Control questionnaires and obtain any necessary clarifications or
additional information from entity’s management; and
(b) be satisfied that the requirements of the relevant laws and regulations
6.9
5,6
are met.
Where the Member in Business who is at controlling entity level is unable to resolve
matters that have a material impact on the group Management Representations, the
Member should refer those matters to Those Charged with Governance.
6.10 Where a Member in Business who is at controlling entity level is implementing a group
Risk Management Framework, the Member should take reasonable steps to ensure
the group Risk Management Framework:
(a) identifies and manages Fraud Risk factors, financial reporting Risks and
corruption Risks; and
(b) considers non-financial reporting processes that will have an impact on the Group
Financial Reports, either now or in future, e.g. greenhouse gas disclosures,
environmental and sustainability reports and information technology matters.
7.
Management Representation considerations at the board or audit
committee level
7.1
A Member in Business who is at the board or audit committee level should assess the
entity’s or the group’s Management Representation process, by considering whether
the Group Management:
(a) possesses appropriate leadership capabilities;
(b) has appropriate expertise, experience, training and/or education;
(c) exhibits adherence and commitment to appropriate ethical and Professional
Standards;
(d) appropriately monitors, controls and reviews processes; and
(e) effectively documents and communicates policies and procedures.
7.2
A Member in Business who is at the board or audit committee level should evaluate
whether the entity’s or the group’s policies and procedures:
(a) support a strong ethical culture;
(b) establish clearly defined channels for personnel to raise any concerns to Group
Management or Those Charged with Governance in a manner that enables
personnel to come forward without fear of reprisals;
(c) maintain a Risk Management Framework in respect of the provision of quality and
ethical Professional Activities that identifies, assesses and addresses material
Risks; and
(d) implement safeguards in the work environment (e.g. systems of corporate
oversight, ethics and conduct programs, recruitment procedures, strong groupwide controls, appropriate disciplinary processes and quality of employee
performance) to eliminate or reduce threats of non-compliance with the
fundamental principles of the Code.
5
6
For example, Corporations Act 2001: Section 295A.
For example, ASX Corporate Governance Council. Corporate Governance Principles and Recommendations:
Recommendation 4.2.
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APES GN 41 Management Representations
7.3
Where a Member in Business who is at the board or audit committee level is assessing
the adequacy, efficiency and effectiveness of the Management Representations
process, the Member should consider whether management has adequate processes
to monitor the entity’s or the group’s Internal Control environment and information
systems.
7.4
Where a Member in Business who is at the board or audit committee level is unable to
resolve matters that have a material impact on the Management Representations
process, the Member should assess the impact of any deficiencies noted on the entity
or the group’s Internal Control environment, business processes and the resulting
impact on the Group Financial Report.
Financial Reporting Certification considerations
7.5
A Member in Business who is at the board or audit committee level that relies on the
Financial Reporting Certification to meet the Member’s responsibility for the Financial
Statements, should perform an assessment to determine the quality, reliability and
effectiveness of Management Representations.
7.6
Where a Member in Business is part of Those Charged with Governance and has
received declarations from management that the Financial Reporting Certification
7
process is in accordance with legislative or regulatory requirements or a voluntary
equivalent, the Member should consider its reasonableness and assess:
(a) the effectiveness of the entity’s or the group’s strategies and processes adopted
to manage material business Risks and to support the Financial Reporting
Certification;
(b) the feedback provided by internal auditors and external auditors to the board or
audit committee on these business Risks; and
(c) whether the responses from the Financial Reporting Certification are aligned with
the actual circumstances of the group’s operations.
8.
Documentation
8.1
A Member in Business who is preparing and/or signing Management Representations
should prepare working papers that appropriately document the work performed,
including the basis, method, calculations, determinations or estimates used in the
provision of this Professional Activity to the Member’s Employer.
8.2
A Member in Business who is at the board or audit committee level should take
reasonable steps to ensure that:
(a) the entity retains relevant documentation in respect of the key matters considered
and discussed at the board or audit committee meeting; and
(b) the key decisions made at those meetings are appropriately reflected in the
minutes of the applicable meeting.
Conformity with International Pronouncements
The International Ethics Standards Board for Accountants (IESBA) has not issued a
pronouncement equivalent to APES GN 41.
7
For example, Corporations Act 2001:Section 295A.
11